Project co-financed by European Union Project co- financed by Asean ASEAN GMP TRAINING MODULE INTERNAL AUDIT Prepared by: Lam Kok Seng - Singapore Approved by: ASEAN Cosmetics GMP Team Endorsed by: ASEAN Cosmetic Committee European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 1 Project co-financed by European Union CONTENT OF PRESENTATION Project co- financed by Asean TABLE OF CONTENT European Committee for Standardization Implementing Agency a. Introduction Objectives Description of Internal Quality Audit Scope of IQA Benefit of IQA The key principle of internal audit The role of internal audit Quality audit documentation b. Managing the internal audit program Process flow for the management of an audit program Authority for internal audit program Establishing the audit program Audit program implementation Monitoring and reviewing the audit program c. Audit activities Overview of audit activities Initiating the audit Conducting document review Preparing for on-site audit activities Conducting on-site audit activities Preparing, approving, and distributing the internal audit report Completing and conducting audit follow-up d. Conclusion e. References Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 2 Project co-financed by European Union Project co- financed by Asean INTRODUCTION European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 3 Project co-financed by European Union OBJECTIVES Project co- financed by Asean To define the activities and requirements of IA To identify the roles and benefits of IA in a quality management system To learn how to plan, perform and monitor IA European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 4 Project co-financed by European Union DEFINITION Project co- financed by Asean “Internal Audit" is an independent examination of a quality system It measures the effectiveness of an organisation's quality management system. It is a documented and systematic tool It should be done periodically by independent and qualified people “Audit" itself is a checking system, NOT a quality assessment As a communication tool of management policies. All personnel have to understand and do their jobs well European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 5 Project co-financed by European Union ROLES OF IA As a powerful tool to measure the effectiveness of quality management system Evaluates manufacturer’s compliance with GMP in all aspects related production and quality control Detects any shortcomings in the implementation of GMP Recommend the necessary corrective and preventive actions European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 Project co- financed by Asean 6 Project co-financed by European Union SCOPE OF IA (1) Project co- financed by Asean Ensures quality in design, approval, monitoring and evaluation of products should comply GMP requirements Ensures quality in GMP implementation and its strategies Ensures quality in appointment, development and performance of staff and key personnel Ensures quality in obtaining and responding to the feedbacks from customers, consumers, employers, employees, government authority and other relevant institutions European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 7 Project co-financed by European Union SCOPE OF IA (2) Includes all written quality documents, instructions and records Covering all elements of GMP including results of previous internal quality audit and any corrective and preventive actions (CAPA) taken European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 Project co- financed by Asean 8 Project co-financed by European Union BENEFITS OF IA Tells you the health of a quality system Identify the root of a problem and plan for corrective and preventive actions with timeline Achieve better allocation of resources Able to avoid potentially big problem Learn what an auditors look for Continuous improvement European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 Project co- financed by Asean 9 Project co-financed by European Union KEY PRINCIPLES OF IA Project co- financed by Asean Approaches towards IA: • Independent • Evidence-based approach All activities related to IA should: • be reviewed by an independent party • be a self-appraisal system • have a sampling plan and tracking system • be open, constructive and effective Strategies in conducting audit: • Ask with the basic audit questions about the quality system in place • Start with what, why, how, who, where, when European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 10 Project co-financed by European Union PRINCIPLE OF AN AUDITOR Project co- financed by Asean Ethical Professional Fair European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 11 Project co-financed by European Union Project co- financed by Asean GUIDANCE WHEN CONDUCTING AN AUDIT • Auditing should be seen as a positive process not a fault finding • Audits need to be documented • Prior to the audit date, an auditor needs to review the quality system documentation, corrective and preventive actions, and past audit findings and develop a checklist • During an audit, an auditor need to see evidences that the processes are being done in accordance to procedures and policies European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 12 Project co-financed by European Union GUIDANCE FOR AUDITEE Project co- financed by Asean When being audited: • • • • • European Committee for Standardization Implementing Agency Volunteer information Report deficiencies and difficulties if you know of any Be honest, open and cooperative Ensure that underlying causes are identified Ask the auditor if you’re not sure Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 13 Project co-financed by European Union Project co- financed by Asean MANAGING IA European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 14 Project co-financed by European Union Project co- financed by Asean FLOW CHART OF IA Authority for the audit programme Establishing the internal audit program obectives responsibilitties resources procedure and guidance Act Improving the audit programme Implementing internal audit program scheduling audits evaluating auditors selecting audit team directing audit activiries maintaining records Plan competence and evaluation of auditors Audit activities Monitoring & reviewing the internal audit program monitoring & reviewing identifying needs for corrective identifying needs for prevention actions identifying opportunities for improvement European Committee for Standardization Implementing Agency Do Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 Check 15 Project co-financed by European Union RESOURCES FOR IA Project co- financed by Asean Considerations should be given to the following: Resources Audit techniques Processes to achieve and maintain the competency of auditors and to improve their performance Competency and availability of auditor Available time for auditing European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 16 Project co-financed by European Union IA OBJECTIVES PLANNING Project co- financed by Asean The planning of IA consists of : • Authority for administering the IA program • Establishing IA program European Committee for Standardization Implementing Agency Objectives Responsibility Procedure and guidance Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 17 Project co-financed by European Union IA IMPLEMENTATION Project co- financed by Asean The implementation of IA program consists of : European Committee for Standardization Implementing Agency Scheduling audit Implementation of audit program Audit record and report Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 18 Project co-financed by European Union IA MONITORING • • Project co- financed by Asean Implementation of audit program should be monitored at appropriate intervals and reviewed to assess whether its objectives have been met and identified opportunities for improvement. Auditing findings should be reported to the management. European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 19 Project co-financed by European Union Project co- financed by Asean AUDITING ACTIVITIES European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 20 Project co-financed by European Union OVERVIEW OF AUDIT ACTIVITES Project co- financed by Asean Planning and scheduling audit Conducting document review Preparing for on-site activities Conducting audit Prepare audit report Conducting follow-up European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 21 Project co-financed by European Union AUDIT ACTIVITIES • Forming an audit team and assign roles and responsibility and agreed on the scope • Conducting document review Review documents (SOPs, audit findings, Project co- financed by Asean corrective action/preventive action, etc.), check the integrity of the quality system and various controls are effective • Preparing for the on-site audit activities Preparing audit plan Assigning work to the audit team Preparing work documents (eg. audit checklists, sampling plans, forms for recording information; questionnaires) European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 22 Project co-financed by European Union AUDIT DOCUMENTATION Project co- financed by Asean • Audit plan should be sent to auditee prior to audit activity findings from the last audit should be also mentioned • Audit note should include an audit questionnaire all records and comments during the audit • Audit report is an official document to report the audit findings European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 23 Project co-financed by European Union EXAMPLE OF AN AUDIT CHECKLIST • Project co- financed by Asean General format for an audit checklist European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 24 Project co-financed by European Union EXAMPLE OF AN AUDIT CHECKLIST Date Auditor CHECKING LIST FOR GMP ASSESSMENT DESCRIPTION Personnel : : Location Auditee Storage area GMP.REF. 1.2.1 5.1.2 2.1.5 10.1.1 3.1 3.6 3.9 & 3.10 3.12.2 Sanitation 3.1 5.3 Documentation 4.3 10.2.2.3 10.2.2.1 European Committee for Standardization Implementing Agency PARAMETER - Organization structure - Personnel hygiene - Training record - Design and layout of defined area - Flow of personnel and goods - Structure of the storage area, based on GMP - HVAC system - Record of monitoring parameter - Pest record program - The map of bait - The cleanliness of weighing apparatus - Record of maintenance and calibration of weighing apparatus - The effectiveness of label system - Inventory stock control Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 Project co- financed by Asean : Warehouse : AUDIT FINDING 25 Project co-financed by European Union IA MONITORING Project co- financed by Asean INTERNA: AUDIT QUESTIONAIRES Area audited : ______________________ Date: __________________ Question (QSR-GMP Reference) Response 1. Does the company have a work instruction to operate the machine? 2. How is the machine being cleaned and maintained? 3. Are personnel trained to use the machine? 4. How often is the equipment being calibrated and cleaned? 5. When is the last breakdown of the machine? Are there any product being affected? European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 26 Project co-financed by European Union Project co- financed by Asean AUDITING ACTIVITIES (1) • Conducting on-site audit activities Conduct opening meeting Good communication during the audit Roles of escort and observer Steps in conducting on site audit: European Committee for Standardization Implementing Agency Interviews with different personnel Carry out both horizontal and vertical audits. Focus on safety and quality of product. Use “Trace-back” method Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 27 Project co-financed by European Union Project co- financed by Asean AUDITING ACTIVITIES (2) • Generating audit findings Either conformity or non-conformity Sort out isolated or systemic deficiencies Isolated deficiency: Tends to happen randomly; no meaningful pattern; rarely happens Systemic deficiency: Could be connected to a particular process, product, material, person or organisation; shows pattern; happens more than once European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 28 Project co-financed by European Union Project co- financed by Asean ISOLATED VERSUS SYSTEMIC DEFICIENCY NON CONFORMANCE DEFICIENCIES ISOLATED SYSTEMIC Latex gloves rip SOP contains an error Wrong expiration date written on a reagent bottle Batch record is poorly written so instruction can be confusing Operator or lab technician spills a sample Area management does not reinforce requirement to continually record information properly Pressing machine of eye shadow burns out Preventive maintenance program does not include liquid filling machine motor European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 29 Project co-financed by European Union AUDIT MONITORING Project co- financed by Asean The audit finding can be classified into 2 groups: 1. Compliance : a. Satisfactory /Adequate b. Outstanding 2. Non-compliance : a. Critical deficiency b. Major deficiency c. Minor deficiency European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 30 Project co-financed by European Union AUDIT REPORT European Committee for Standardization Implementing Agency Project co- financed by Asean Objectives Audit scope Identification of audit team leader and members Date and place where the on-site audit activities were conducted Audit criteria and findings Conclusions Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 31 Project co-financed by European Union AUDIT REPORT Project co- financed by Asean Various formats can be used depending on auditee (vendors, management or auditee) Usually include name and location of auditee, date of audit, audit plan, audit observations, classification of non-compliances, recommendations or expectations Should write against a standard Focus on deficient conditions and not people Include any positive observations Keep the audit report simple and clear European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 32 Project co-financed by European Union Project co- financed by Asean AUDIT REPORT: AN EXAMPLE No GMP.Ref Findings of IA 1. 2.1.1 Production and QC departments are headed by the same person Critical Human Resources Abas Budi 2. 4.3 Monitoring of temperature in a warehouse Major or Minor Warehouse Tuti May Lin 3 11.1 Inadequate control over sub-contractor Major or Minor Production Herman Ida European Committee for Standardization Implementing Agency Grading Location Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 Auditee Auditor 33 Project co-financed by European Union Project co- financed by Asean CLOSURE Follow-up and closing of loop: • Receive a satisfactory response from auditee and their commitment to correct for any deficiency • Ensures CAPA identify the root cause and they are satisfactory, accomplished and documented • Timeframe for CAPA is being followed • Verify and track CAPA by scheduling a follow-up audit and/or requesting for an updated SOP European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 34 Project co-financed by European Union Project co- financed by Asean CONCLUSIONS Nobody likes to be audited……….. It is a means to have continuous improvement European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 35 Project co-financed by European Union RELATED HYPERLINK DOCUMENTS Project co- financed by Asean Trainer Manual of Internal Quality Audit European Committee for Standardization Implementing Agency Module 9 GMP Workshop Kuala Lumpur 14-16 Nov 2005 36 Project co-financed by European Union REFERENCES 1. 2. 3. 4. 5. 6. 7. European Committee for Standardization Implementing Agency Project co- financed by Asean ASEAN Guidelines for Cosmetic GMP. International standard ISO 9001:2002, Guidelines for quality and/or environmental management system auditing, 1st Edition, 2002 www.cityu.edu.hk, Internal Quality Audit Scheme. www.fineprint.com, Internal Audit Procedure Stimson W.A., Internal Quality Auditing, Meeting the challenge of ISO 9000:2000, Paton Press, 2001 WHO – EDM, Basic Principle of GMP: SelfInspection. 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